What is the fundamental difference between speech rights in the United States and Europe?

In the United States, speech rights are inherent and do not flow from the government. The First Amendment simply recognizes that Americans possess intrinsic freedoms of thought, conscience, and assembly, which the government acknowledges rather than grants. In contrast, European speech rights operate under a fundamentally different concept. Rights in Europe flow from the state, meaning they can be granted or taken away according to governmental discretion. This distinction creates a more conditional approach to free expression in Europe compared to America's constitutional protection, making European speech rights more vulnerable to restriction when governments determine limitations are necessary.